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Scoping Memo Issued in SDG&E PSW/PSW Rate Hike Proposal at CPUC
California Public Utilities Commissioner Nancy E. Ryan issued the scoping memorandum at the end of September for San Diego Gas and Electric Company's rate hike proposal A1007009. SDG&E's PeakShift at Work/PeakShift at Home rate hike proposal is based on time of usage and designed to force small business and residential customers from the business-time peak power market. Hearings on evidence are scheduled in San Francisco for March 2011, and the due date on a proposed Decision by CPUC's Ryan and Administrative Law Judge Jessica T. Hecht is July 2011.
Under the A1007009 proposal, SDG&E's residential and small business customers will be billed by time of electricity usage under PeakShift at Work/PeakShift at Home (PSW/PSH) rates at up to ten times the off-peak rates for evening and weekends. Opposition against PSW/PSH centers on the lack of any quantitative analysis by SDG&E indicating that its proposal actually provides net benefits to customers and is cost effective. Also, PSW/PSH approval amounts to a countywide experiment in social design by imposing higher costs for using energy during business hours and forcing popular usage increases during non-peak hours. Despite lack of notice by local chambers of commerce, PSW appears to be anti-competitive for small business power customers, and the proposal comes at a time when local and national economic conditions point to a sustained period of anemic economic growth or no growth at all.
Part of SDG&E's proposal is a cost recovery request to bill customers $118 million in advertising and other related costs for SDG&E to inform small business and residential consumers of PSW/PWH rates. Despite the millions requested from customers for advertising, SDG&E attorneys insist that PSW/PSH terminology has been designed to be easily understood by ratepayers.
Parties in opposition to the A1007009 application already include CPUC's Division of Ratepayer Advocates (DRA), the Utility Consumers’ Action Network (UCAN), the City of San Diego, and Disability Rights Advocates.
Smart meters are a key component of PSW/PSH, and smart meters provide the ability for the local power utility to power down smart appliances tied to the smart grid. Smart meters have shown themselves to be problematic in certain San Diego neighborhoods when receiving software updates, and earlier smart meter versions have been shown to be vulnerable to circumstances similar to computer hacking over the Internet. Under the PSW/PSH proposal by SDG&E and without human meter readers employed anymore, SDG&E must base monthly billings at variable rates on the credibility of smart meters that appear to have a rather short mean time before failure.
In the Pacific Gas and Electric Company service area, at least one customer has filed an application to re-visit previous CPUC decisions allowing smart meters in and around San Francisco and other PG&E service areas, insisting that the utility rather than ratepayers pay for the electricity meter replacements. The consumer application to reconsider previous CPUC smart meter decisions comes at a time when PG&E faces severe criticism and extensive liability for the explosive catastrophic failure of a high-pressure gas transmission line in the suburban neighborhood of San Bruno.